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Slavery and Human Trafficking Statement

This statement is made by AXA Liabilities Managers (“AXA LM”) (the “Company”) pursuant to Section 54 of the UK Modern Slavery Act 2015 (“the MSA”). It sets out the steps that the Company has taken during the 2016 financial year to combat and prevent all forms of modern slavery and human trafficking in its business and supply chains. This statement covers the Company’s direct operations and supply chains.

The AXA Group has a long history of adhering to and promoting strong professional ethics and is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing such ethical standards is designed not only to ensure compliance with applicable laws and regulations in the various jurisdictions where AXA operates but also to earning and keeping the continued trust of its clients, shareholders, personnel and business partners. AXA believes that its success and reputation are not only dependent on the quality of its products and the services provided to its clients, but also on the way it does business. This includes a strong commitment to human rights and therefore, it welcomes the transparency promoted by the MSA.

1. Company’s structure and business

AXA LM was established in 2001, to manage the AXA Group’s run-off reinsurance portfolios. It specialises in the acquisition and management of non-life legacy (re)insurance business. It is headquartered in Paris, with teams in the USA, UK and Switzerland.

2. Company’s supply chains

The Company purchases products and services for the purpose of its internal operations. Its main supply chains, for example in respect of IT and related services, are internal to the AXA Group.

Each of the Company’s teams (in France, the USA, UK and Switzerland) has reviewed its third party (non-AXA Group) suppliers, in order to assess the nature of the products or services supplied and the risk of slavery or human trafficking.

3. Engagements and policies in relation to modern slavery and human trafficking

The AXA Group is committed to respecting internationally recognized human rights principles as defined by the United Nations Universal Declaration of Human Rights, the core standards of the International Labour Organisation and the Guiding Principles for the implementation of the United Nations “Protect, Respect and Remedy” Framework (the Ruggie Principles). The AXA Group is also committed to applying international general and sector-specific standards such as the UN Principles for Responsible Investment, the UN Principles for Sustainable Insurance and the UN Global Compact (“UN GC”). Since 2003, AXA adheres to the UN GC and has formally committed to promoting its ten guiding principles, including those on human rights (such as avoiding complicity in human rights abuses and supporting and respecting the protection of internationally proclaimed human rights) and labour standards (such as supporting the elimination of all forms of forced and compulsory labour and the effective abolition of child labour).

In addition, the AXA Group has put in place policies to support its commitment to ethical business practices across the organisation. These include:

• The AXA Group Human Rights Policy , which aims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out AXA’s commitment to identify, prevent and/or mitigate adverse indirect human rights impacts that are linked to its operations or services, through its business relationships or projects it has invested in or insured.

• The AXA Group Compliance and Ethics Guide (the “Guide”) , which establishes guiding principles and Group-wide policies designed to ensure that all AXA Group companies and their personnel have a common vision of the Group’s ethical standards (including the UN GC principles on human rights, labour standards, environment and anti-corruption) and operate in accordance with those standards. All AXA employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or inconsistent with any of the policies set out in the Guide through their local whistleblowing procedures. Senior officers of AXA entities are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide.

The AXA Group Human Rights Policy, the Guide, and the principles and standards mentioned above, all apply to the Company.

4. Management of modern slavery and human trafficking risk in the Company’s operations

AXA LM acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. The Guide sets out protections for AXA’s employees and their rights. In particular, it emphasises that:

• AXA is committed to upholding the right of freedom of association and collective bargaining, as well as maintaining constructive labour management relations in every country in which it does business, and to doing so with due respect for different national approaches to social dialogue;

• AXA respects the rights of its employees to enjoy just and favourable conditions of work, including health and safety protections, and is committed to providing adequate information and training on health and safety and wellbeing issues.

In addition, AXA promotes diversity and inclusion by prohibiting any form of discrimination between current, past or potential staff on the basis of age, race, nationality, ethnic origin, gender, sexual orientation, religion, marital status or disability. The Company has a Diversity and Inclusion Executive Sponsor and its D&I Governance Group meets twice yearly, to exchange best practice across all its locations. A global D&I coordinator connects AXA LM with AXA Group D&I on a regular basis.

5. Assessment of the Company’s suppliers and due diligence process in relation to the Company’s supply chains

AXA ensures that it works with suppliers that meet its standards with respect to ethics and corporate responsibility through a clearly documented process for supplier selection and contracting.

In accordance with such process, the Company seeks to ensure that its standard contractual terms with suppliers include specific reference to AXA’s corporate responsibility requirements, and suppliers will be required to provide a formal commitment to uphold the core standards of the UN GC by signing AXA’s “Corporate Responsibility clause”. Notably, suppliers have been asked to agree to refrain from using, or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour.

Detection of a direct or indirect violation by the supplier of the AXA corporate responsibility requirements will be discussed directly with the supplier with a view to establishing a mutually agreed and documented corrective action plan. Where any issue is not resolved satisfactorily, the Company reserves the contractual right to end its relationship with the relevant supplier.

6. Training and information available to staff

The Company plans to roll-out an awareness training programme for employees involved in procurement, to give them a detailed knowledge of AXA’s corporate responsibility principles. This training programme will highlight the instrumental role of responsible procurement in order to ensure that the Company engages with responsible suppliers.

The Company’s Executive Committee approved this statement on 13 June 2017, which constitutes the Company’s Slavery and Human Trafficking Statement for the financial year ending 31 December 2016.

Data Privacy

AXA Liabilities Managers is part of the AXA Group (France) and has offices in various countries. The handling of business processes is partially carried out across borders in central service units where synergies are used to achieve cost saving. Processing of data outside the European Union or Switzerland takes place on the basis of AXA Group guidelines (Referred to as Binding Corporate Rules) which have been approved by the European Data Protection Authorities. These rules ensure an appropriate level of data protection for information processed by AXA companies domiciled outside the European Union and Switzerland.

Personal information communicated to AXA by Internet users on the AXA Group's sites, by way of forms or questionnaires placed on line, is necessary for the processing of these forms and questionnaires.

It will be analyzed and passed on to the various departments concerned to be handled by them. Unless you raise an objection, AXA may process this information for sales operations.

Rights of Persons concerned (information, complaints, etc.)

In the event that AXA has collected and stored any personal data, in accordance with AXA policy and the French data protection law no. 78-17 dated 6th of January 1978 on computer information, files and civil liberties, you will be entitled:

  • Access and information about the data
  • Modification and correction of the data
  • Removal/locking of the data
  • Submit complaints or make comments about the processing of the data.

Contact
Please direct all requests related to Data Privacy and Binding Corporate Rules to:

AXA Liabilities Managers HR and Communications Department
39, rue du Colisée
75008 Paris France

Email : axa-lm@axa-lm.com

Please remember to include “Data Privacy" and/or "Binding Corporate Rules” in the subject line of the email.